In the News

NERC Self-Reporting: How to Make the Best of a Bad Situation

by Daniel Jenkins – NERC Reliability Specialist, NAES Corporation

From time to time, we all find ourselves in the awkward position of having to admit we made a mistake. It could be something minor, like forgetting your key card to get into work – or something bigger and messier, like a NERC violation. NAES holds itself to the highest standards of safety and reliability in operating power plants, and with that comes a commitment to regulatory compliance. If you’ve identified a possible NERC violation at your facility, here are some suggestions on how to proceed and what you might expect.

First, don’t hold back: share your concern immediately. Let your plant manager, compliance manager and corporate support personnel know as soon as possible. They can help determine what the issue is and what corrective action should be taken. If there’s a possible violation of a NERC Standard or Requirement, we support the NERC guidance that recommends filing a Self-Report. It demonstrates a strong culture of compliance and a proactive approach to maintaining reliability.

Second, start an internal investigation of the event immediately by gathering evidence, documentation and statements from all personnel who had any involvement in the event. With this information in hand, you can put together a timeline and review the scenario to determine if there has in fact been a NERC violation. As part of your investigation, create a list of possible root causes. These will help your team brainstorm preventive measures to avoid a recurrence of similar actions or inaction. They can also be included in a Mitigation Plan, if your Regional Entity determines that you need to submit one. (More about that later.)

Once you know exactly what has happened, you should start your Self-Report. To put it in proper contexts, note the NERC Rules of Procedure: a Self-Report should be filed ‘when a Registered Entity becomes aware that it has or may have violated a Reliability Standard or when the Violation Severity Level of a previously reported violation has changed.’

The Rules of Procedure also set forth a specific protocol to be followed once a Self-Report is filed. When your Regional Entity’s compliance department receives it, they will complete a Preliminary Screening within five days. If the screening determines that 1) the entity is a registered entity, 2) the standard being reported is applicable to the entity, and 3) there is not a duplicate possible violation currently being processed, the Self-Report will be moved on to the Enforcement Actions process. From there, the Regional Entity will further evaluate it and issue either a Compliance Exception; a Find, Fix and Track; or a Notice of Alleged Violation, depending on the severity and risk of the non-compliance.

In the end, your Regional Entity should feel confident that you have both corrected the issue and taken internal actions to prevent a recurrence. If you haven’t demonstrated this convincingly in your Self-Report, you may be required to submit a formal Mitigation Plan, which will need to be approved and then tracked. When all actions have been completed, you’ll receive a Notice of Completion of Enforcement Action to close out the violation. Your organization should then review this process in order to document lessons learned, develop internal controls and take any other action deemed necessary to support continuous improvement.

TPL-007 establishes planning criteria for induced currents caused by geomagnetic disturbances. The standard is applicable to facilities using transformer(s) with a high side, wye grounded winding operated above 200 kV and can require both submittal of general geomagnetic data (R2) and thermal impact assessments (R6) depending on results of Planning Coordinator analysis.

PER-006 requires Generator Operators to provide training to personnel who are responsible for the Real-time control of a generator. NAES has developed specific protection system training materials suitable for compliance with the Standard and provides this training both on and off site

PROTECTION AND CONTROL (PRC) STANDARDS

PRC-001

PRC-001 requires entities to coordinate protection system changes with other affected parties. NAES offers both procedural documentation and engineering services to establish the required coordination for both PRC-001 and PRC-027.

PRC-002

PRC-002 requires the installation and operation of disturbance monitoring equipment (DME) for applicable entities. NAES can assist with the design and installation of DME as well as ongoing compliance support.

PRC-023 requires load responsive protective relays be set according to criteria within the Standard to ensure settings do not limit transmission loadability. NAES provides full engineering analyses to maintain compliance with this Standard.

PRC-025 establishes minimum settings requirements for load-responsive relays protecting generators, step up transformers, and auxiliary transformers. NAES utilizes predefined calculation options as well as simulations to determine a facility’s compliance status and development of new relay settings if required.

PRC-026

PRC-026 requires applicable entities to perform load responsive relay settings analyses based on criteria identified within the Standard. Entities are typically notified by the Planning Coordinator when an analysis is required. NAES performs all required studies to establish compliance.

MODELING, DATA, AND ANALYSIS (MOD) STANDARDS

MOD-025

MOD-025 requires Real and Reactive Power capability testing for individual generating units over 20 MVA or facilities with over 75 MVA of generation capacity. NAES offers site specific test procedures and/or complete onsite testing services to meet the requirements of this standard.

MOD-026

MOD-026 requires verification of excitation or volt/var control dynamic models through utilization of either system disturbances or physical testing. NAES offers full testing and modeling services to meet the requirements of this standard.

MOD-027

MOD-027 requires verification of governor or active power/frequency control dynamic models through utilization of either system disturbances or physical testing. NAES offers full testing and modeling services to meet the requirements of this standard.